BANK SECRECY ACT AND ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM

Introduction

Byte Federal, LLC (“we” or “our”) has developed a Bank Secrecy Act and Anti-Money Laundering Compliance Program (“BSA/AML Program”) for our digital asset services (collectively, “BF”), in an effort to maintain the highest possible compliance with applicable laws and regulations relating to anti-money laundering in the United States. This includes, but is not limited to

  • Establishing robust internal policies, procedures and controls that strive to combat any attempted use of BF for illegal or illicit purposes and to ensure our customers basic protections under consumer protection laws
  • Complying with the applicable regulations and guidance set forth by the Financial Crimes Enforcement Network (“FinCEN”)
  • Filing Suspicious Activity Reports (“SARs”)
  • Filing Currency Transaction Reports (“CTRs”)
  • Maintaining comprehensive records of orders and other transfers
  • Employing a Chief Compliance Officer (“CCO”) who is responsible for the implementation and oversight of our BSA/AML Program
  • Executing Know Your Customer (“KYC”) procedures on all customers
  • Performing regular, independent audits of our BSA/AML Program
  • Following record retention requirements
  • Implementing a formal and ongoing compliance training program for all new and existing employees

Policies and Procedures

Our BSA/AML Program has been reviewed and approved by our Executive Team (the “Team”). Our BSA/AML Program is regularly reviewed and, if necessary, revised in an effort to comply with applicable rules, regulations and policies.


Account Opening Process

In order to our services, your identity must be verified, authenticated, and checked against government watchlists, including the Office of Foreign Assets Control (“OFAC”). Failure to complete any of these steps will result in your inability to use BF. Individual customer — When creating a user account for an individual customer, we attempt to collect, verify, and authenticate the following information:

  • Mobile phone number
  • Full legal name
  • Date of birth (“DOB”)
  • Proof of identity (e.g., driver’s license, passport or government-issued ID)
  • Home address (not a mailing address or P.O. Box); and
  • Additional information or documentation at the discretion of our Compliance Team.
If you successfully meet and complete our CIP requirements and do not appear on the OFAC or any other government watchlist, then we will provide you with a user account.


Suspicious Activity / Currency Transaction Reports

We file SARs if we know, suspect or have reason to suspect suspicious activities have occurred on BF. A suspicious transaction is often one that is inconsistent with a customer’s known and legitimate business, personal activities or personal means. We leverage our compliance department, which performs transaction monitoring to help identify unusual patterns of customer activity. Our CCO reviews and investigates suspicious activity to determine if sufficient information has been collected to justify the filing of a SAR.

In addition, all currency transactions over a determined USD value are be reported to FinCEN via a CTR filing.

Our CCO maintains records and supporting documentation of all SARs and CTRs that have been filed.


Internal Controls

We have developed robust internal policies, procedures, and controls designed to comply with applicable BSA/AML laws and regulations, some of which are outlined here on this page including, but not limited to, our Customer Identification Program (“CIP”), the filing of SARs and CTRs, as well as other reporting requirements and audits.


Training

All of our employees and officers receive ongoing broad-based BSA/AML training, as well as position-specific training. They must repeat this training at least once every twelve (12) months to ensure they are knowledgeable and in compliance with all pertinent laws and regulations. New employees receive training within thirty (30) days of their start date. All documentation related to compliance training including materials, tests, results, attendance and date are maintained. In addition, our compliance training program is updated as necessary to reflect current laws and regulations.


Compliance Officer

Our CCO is responsible for developing and enforcing the policies and procedures of our BSA/AML Program. Our CCO is required to report any violations of our BSA/AML Program directly to our Team. In addition, our CCO is responsible for recording and filing SARs, CTRs and performing a BSA/AML Program audit at least annually.


Customer Identification

Our Customer Identity Program (“CIP”) is an important part of our BSA/AML Program, and helps us detect suspicious activity in a timely manner and prevent fraud.


Reporting Requirements

All records are retained for seven (7) years and are readily available upon official request by an applicable examiner, regulator, or law enforcement agency.


BSA/AML PROGRAM AUDIT

Internal

The CCO is responsible for performing an audit of our BSA/AML Program at least annually, and presenting the results to our Team.

Independent

Our CTO oversees the performance of an independent test of our BSA/AML Program at least annually. The CCO is not responsible for the independent test, and the CCO’s performance is a subject of the test. Results are sent directly to the Team for review.